Bissonnette v. LePage Bakeries Park St., LLC

Neal Bissonnette and Michael Wojnarowski were delivery drivers for LePage Bakeries Park St., LLC, a subsidiary of Flowers Foods, distributing baked goods to stores. They sued for unpaid overtime under federal and state law. The employer moved to compel arbitration based on their contracts. The district court denied the motion, but the Second Circuit reversed, holding that the Federal Arbitration Act's Section 1 exemption for transportation workers did not apply because the drivers worked for a bakery, not a transportation company. The U.S. Supreme Court granted certiorari and unanimously reversed on April 12, 2024, holding that the exemption focuses on the nature of the work performed, not the employer's industry.

The Supreme Court unanimously reversed the Second Circuit, holding that the transportation worker exemption turns on the work the employee performs, not the employer's industry. Bissonnette and Wojnarowski were deemed transportation workers exempt from mandatory arbitration, and the case was remanded for further proceedings.

Whether the Federal Arbitration Act's Section 1 exemption for "workers engaged in foreign or interstate commerce" applies only to employees of transportation companies, or also to workers whose duties involve interstate transportation regardless of their employer's primary business.

The ruling broadens the scope of the transportation worker exemption under the Federal Arbitration Act, making it harder for companies to force delivery drivers and similar gig economy workers into arbitration. It clarifies that worker protections depend on job duties rather than the employer's business classification, potentially affecting many independent contractor and transportation-related labor disputes.